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Switzerland: Lino Sergi et al (‘Fraud & Misappropriation’)

Application for the appointment of a Commissioner to collect evidence from Uber - pursuant to a request for judicial assistance from Switzerland - for a criminal investigation into "Lino Sergi and Daniela Lucanto for fraud, misappropriation, and driving on a suspended license".

Switzerland: Citibank (‘Fraud & Forgery’)

Application for the appointment of a Commissioner to collect evidence from Citibank - pursuant to a request for judicial assistance from Switzerland - for a criminal investigation into "unknown suspects for fraud and forgery of documents".

Panama: Héctor Dáger (‘Odebrecht SA $28M Corruption & Money Laundering’)

Application for an order authorizing the disclosure of Grand Jury materials (BAC Florida Bank records) to Panama for use in a criminal investigation into Héctor Dáger, described as "a Venezuelan citizen with Panamanian residency permit", for "potential corruption and money laundering relating to contracts obtained by the Brazilian company Odebrecht S.A. from the government of Venezuela".

CFTC v. Changpeng Zhao et al: Complaint

Complaint regarding "the world’s largest centralized digital asset exchange" in Commodity Futures Trading Commission v. Changpeng Zhao, described as a citizen of Canada residing in Dubai; Binance Holdings Limited, of the Cayman Islands; Binance Holdings (IE) Limited, of Ireland; Binance (Services) Holdings Limited, of Ireland, and Samuel Lim, described as a resident of Singapore, at the U.S. District Court for the Northern District of Illinois.

SIIS Holdings Ltd. v. Samumed LLC: Complaint

Complaint "to enforce its right to inspect books and records to investigate potential mismanagement and breaches of fiduciary duty in connection with the Company’s involvement in the solicitation and inducement of the sale and purchase of equity interests in the Company" in SIIS Holdings Ltd., of the Cayman Islands v. Samumed LLC, described as "a biotechnology company that was founded in 2008 by Osman Kibar and is engaged in business of researching and developing drugs with a focus on osteoarthritis and oncology", at the Court of Chancery of the State of Delaware.

Lina Molokotos-Liederman v. Thanasis Molokotos et al: Complaint (‘$5M BVI Trust Fund Fraud’)

Complaint alleging "a complex, international scheme by which Plaintiff’s family, including her mother Helen Stassinopoulos Molokotos, brother Thanasis Molokotos, and sister-in-law Diane Vardakas Molokotos, have absconded with millions of dollars in assets placed into trust for Plaintiff’s benefit" in Polyxeni (Lina) Molokotos-Liederman, of the District of Columbia v. Thanasis Molokotos, of Connecticut; Diane Vardakas Molokotos, of Connecticut; Helen Stassinopoulos Molokotos, described as a citizen of Greece residing in Switzerland; James Spanos, of Connecticut, and Penny Spanos, of Connecticut, at the U.S. District Court for the Southern District of New York.

John Cress v. Nexo Financial LLC et al: Complaint (‘Crypto Fraud’)

Complaint in John Cress v. Nexo Financial LLC, Nexo Financial Services Ltd., of England; Nexo Services OU, of Estonia; Nexo AG, of Switzerland; Nexo Capital Inc., of the Cayman Islands, and Antoni Trenchev at the U.S. District Court for the Northern District of California.

John Harney et al v. Jakov Dolic et al: Complaint (‘Crypto Firm Dispute’)

Complaint in John Harney and DGF Investments Inc., of the British Virgin Islands, individually and derivatively on behalf of Layer1 Technologies Inc., described as "a cryptocurrency mining and technology company" whose "parent and sole stockholder" is Enigma Holding AG, of Switzerland, which has "subsidiaries in the United States, Switzerland, Croatia, and the Bahamas" v. Jakov Dolic and Tobias Ebel, Defendants, and Layer1 Technologies, Nominal Defendant, at the Court of Chancery of the State of Delaware.

Hyperrr.com GmbH: Public Warning (Switzerland)

Public Warning by the Swiss Financial Market Supervisory Authority that Hyperrr.com GmbH is "suspected of conducting unauthorised activities in the financial market".

Crypto lender Nexo Capital sues Cayman regulator for rejecting license application

On the day its offices were raided in Bulgaria last week, and four of its employees criminally charged with money laundering and fraud, the Nexo crypto lending group sued the Cayman Islands Monetary Authority for rejecting its licensing application and is seeking a court declaration that it is "suitable to be registered".

Quotient Ltd.: Chapter 11 Petition

Chapter 11 Petition by Quotient Limited, described as a Jersey, Channel Islands-domiciled company based in Switzerland, filed at the U.S. Bankruptcy Court for the Southern District of Texas.

Avendis Global Fund Ltd. et al v. Coficap SA: Default Costs Certificate Application ($224,153)

Application for Default Costs Certificate in the amount of $224,153 in Glen Trenouth and Malcolm Cohen, both of BDO, as Joint Official Liquidators of Avendis Global Fund Ltd. (in Official Liquidation), Avendis Enhanced Fixed Income Trading Ltd. (in Official Liquidation), and Avendis Global Strategies Trading Ltd. (in Official Liquidation) v. Coficap SA, of Geneva, Switzerland, at the Grand Court of the Cayman Islands

SEC v. Andrew DeFrancesco et al: Complaint (‘Securities Fraud’)

Complaint alleging securities fraud involving entities in several jurisdictions, including the Bahamas, Canada, and USA, in U.S. Securities and Exchange Commission v. Andrew DeFrancesco, Marlio Mauricio Dioaz Cardona, Carlos Felipe Rezk, Nikola Faukovic, and Catherine DeFrancesco, described as "resident of Miami Beach, Toronto, and Gstaad, Switzerland", at the U.S. District Court for the Southern District of New York.

Silver Screen Films Inc. v. Hollywood Media Venture LLC et al: Complaint (‘Fraudulent Movie Financing Scheme’)

Complaint alleging "a fraudulent movie financing scheme" in Silver Screen Films Inc., formerly Silver Screen Finance Inc., of the Cayman Islands v. Hollywood Media Venture LLC, Hollywood Media Ventures I LLC, Hollywood Media Ventures II LLC, Hollywood Media Ventures Holdings LLC, Hollywood Media Ventures Holdings II LLC, Hollywood Media Ventures Management LLC, Hollywood Media Venture Partners LLC, Hollywood Media Venture Productions I LLC, Production Capital LLC, Production Capital Corp., Burgee & Abramoff P.C., Knightsbridge Entertainment Inc., Base FX Productions Switzerland AG, of Switzerland; Kevin Robl, Remington William Chase, Robert William Abramoff, and Mohamed Shaaban at the U.S. District Court for the Central District of California.

Julius Baer International Ltd. et al: £18M Fine & Industry Bans

Public Notice by the United Kingdom's Financial Conduct Authority that it has imposed a fine of £18 million on Julius Baer International Limited "for failing to conduct its business with integrity, failing to take reasonable care to organise and control its affairs and failing to be open and cooperative with the FCA" and banned "Gustavo Raitzin, former Regional Head for Bank Julius Baer, Thomas Seiler, former BJB Sub-Regional (Market) Head for Russia and Eastern Europe and JBI non-executive director, and Louise Whitestone,former relationship manager on JBI’s Russian and Eastern European Desk".

Louise Blouin et al v. USA: Complaint (‘Trust Fund Taxes’)

Complaint "to strike off certain Federal Tax Liens that were purportedly or attempted to be filed against property owned by Aberdeen Enterprises, Inc., a Delaware Corporation, as a result of an attempt by the Internal Revenue Service to collect on behalf of the United States certain Trust Fund Recovery Penalties, 26 U.S.C. § 6672 purportedly imposed against Louise Blouin" in Aberdeen Enterprises Inc., described as a Delaware company owned by a British Virgin Islands company, and Louise Blouin, a citizen of Canada residing in Switzerland v. USA at the U.S. District Court for the Eastern District of New York.

FTX Trading Ltd. et al: Affidavit Supporting Chapter 11 Petitions (‘Complete Absence of Trustworthy Financial Information’)

Affidavit of John J. Ray III, including statements that "Never in my career have I seen such a complete failure of corporate controls and such a complete absence of trustworthy financial information as occurred here" and "related party loans" were made to Sam Bankman-Fried, $1 billion; Nishad Aingh, $543 million, and Ryan Salame, $55 million, in support of Chapter 11 Petitions by 102 entities comprising the FTX crypto group, including those in Antigua and Barbuda, Australia, Bahamas, British Virgin Islands, Canada, Cayman Islands, Cyprus, Egypt, Germany, Ghana, Gibraltar, Hong Kong, India, Ireland, Japan, Kenya, Liechtenstein, Nigeria, Panama, Senegal, Seychelles, Singapore, South Africa, South Korea, Switzerland, Tanzania, Turkey, Uganda, United Arab Emirates, USA, and Vietnam, filed at the U.S. Bankruptcy Court for the District of Delaware.

FTX Trading Ltd. et al: Motion to Transfer & Stay Chapter 15 Petition

Emergency Motion to Stay and Transfer Chapter 15 Petition from New York to Delaware by 101 entities (reduced from 134 identified in the Chapter 11 Petition) comprising the FTX crypto group, including those in Antigua and Barbuda, Australia, Bahamas, British Virgin Islands, Canada, Cayman Islands, Cyprus, Egypt, Germany, Ghana, Gibraltar, Hong Kong, India, Ireland, Japan, Kenya, Liechtenstein, Nigeria, Panama, Senegal, Seychelles, Singapore, South Africa, South Korea, Switzerland, Tanzania, Turkey, Uganda, United Arab Emirates, USA, and Vietnam, filed at the U.S. Bankruptcy Court for the District of Delaware. In the motion, FTX's new management accused the Bahamas government and regulators of, essentially, misappropriating the group's assets, in conjunction with former FTX principals Samuel Bankman-Fried and Gary Wang, as part of an attempt to "undermine these Chapter 11 Cases".

USA v. Carlos Kepke: USA’s Trial Memorandum (‘Offshore Tax Fraud’)

USA's Trial Memorandum regarding an alleged offshore tax fraud scheme involving accounts or entities in Belize, British Virgin Islands, Cayman Islands, Nevis, and Switzerland that allowed businessman Robert Smith "to evade federal income taxes on approximately $225,000,000 of capital gains" in USA v. Carlos Kepke, an attorney, at the U.S. District Court for the Northern District of California.

FTX Digital Markets Ltd.: Chapter 15 Petition (Bahamas)

Chapter 15 Petition for Recognition of a Foreign Main Proceeding in the Bahamas by Brian Simms, Kevin Cambridge, and Peter Greaves, as the Foreign Representatives of FTX Digital Markets Ltd., which operates "a digital assets business", filed at the U.S. Bankruptcy Court for the Southern District of New York.

FTX Trading Ltd. et al: Motion for Joint Administration (‘More Than One Million Creditors’)

Motion for Joint Administration and Motion Modifying Certain Creditor List Requirements, Authorizing the Debtors to Serve Certain Parties by E-Mail, and Granting Related Relief in the matter of Alameda Aus Pty Ltd., Alameda Global Services Ltd., Alameda Research (Bahamas) Ltd., Alameda Research Holdings Inc., Alameda Research KK, Alameda Research LLC, Alameda Research Ltd., Alameda Research Pte Ltd., Alameda Research Yankari Ltd., Alameda TR Ltd., Alameda TR Systems S. de R. L., Allston Way Ltd., Altalix Ltd., Analisya Pte Ltd., Atlantis Technology Ltd., B for Transfer Egypt, B Payment Services Nigeria, B Transfer Services Ltd., B Transfer Services Ltd. UAE, B Transfer Services Uganda, Bancroft Way Ltd., BitPesa Kenya Ltd., BitPesa RDC SARL, BitPesa Senegal Ltd., BitPesa South Africa, BitPesa Tanzania Ltd., BitPesa Uganda Ltd., Bitvo, Inc., Blockfolio Holdings, Inc., Blockfolio, Inc., Blue Ridge Ltd., BT Payment Services Ghana, BT Payment Services South Africa, BT Payments Uganda, BT Pesa Nigeria Ltd., BTC Africa S.A., BTLS Limited Tanzania, Cardinal Ventures Ltd., Cedar Bay Ltd., Cedar Grove Technology Services, Ltd., Clifton Bay Investments LLC, Clifton Bay Investments Ltd., CM-Equity AG, Corner Stone Staffing, Cottonwood Grove Ltd., Cottonwood Technologies Ltd., Crypto Bahamas LLC, DAAG Trading, DMCC, Deck Technologies Holdings LLC, Deck Technologies Inc., Deep Creek Ltd., Digital Custody Inc., Euclid Way Ltd., Exchange 4 Free Seychellen, Exchange 4Free Australia Br., Exchange 4Free Ltd., Exchange 4Free South Africa Br., Exchange 4Free Swiss Branch, Finfax Company, FTX (Gibraltar) Ltd., FTX Canada Inc., FTX Certificates GmbH, FTX Crypto Services Ltd., FTX Digital Assets LLC, FTX Digital Holdings (Singapore) Pte Ltd., FTX EMEA Ltd., FTX Equity Record Holdings Ltd., FTX Europe AG, FTX Exchange FZE, FTX Hong Kong Ltd., FTX Japan Holdings K.K., FTX Japan K.K., FTX Japan Services KK, FTX Lend Inc., FTX Marketplace, Inc., FTX Products (Singapore) Pte Ltd., FTX Property Holdings Ltd., FTX Services Solutions Ltd., FTX Structured Products AG, FTX Switzerland GmbH, FTX Trading GmbH, FTX Trading Ltd., FTX TURKEY TEKNOLOJİ VE TİCARET ANONİM ŞİRKET, FTX US Derivatives LLC, FTX US Services, Inc., FTX US Trading, Inc., FTX Vault Trust Company, FTX Ventures Ltd., FTX Ventures Partnership, FTX Zuma Ltd., GG Trading Terminal Ltd., Global Compass Dynamics Ltd., Good Luck Games, LLC, Goodman Investments Ltd., Hannam Group Inc., Hawaii Digital Assets Inc., Hilltop Technology Services LLC, Hive Empire Trading Pty Ltd., Innovatia Ltd., Island Bay Ventures Inc., K-DNA Financial Services Ltd., Killarney Lake Investments Ltd., Ledger Holdings Inc., LedgerPrime Bitcoin Yield Enhancement Fund, LLC, LedgerPrime Bitcoin Yield Enhancement Master Fund LP, LedgerPrime Digital Asset Opportunities Fund, LLC, LedgerPrime Digital Asset Opportunities Master Fund LP, Ledger Prime LLC, LedgerPrime Ventures, LP, Liquid Financial USA Inc., LiquidEX LLC, Liquid Securities Singapore Pte Ltd., LT Baskets Ltd., Maclaurin Investments Ltd., Mangrove Cay Ltd., North Dimension Inc., North Dimension Ltd., North Wireless Dimension Inc., Paper Bird Inc., Pioneer Street Inc., Quoine India Pte Ltd., Quoine Pte Ltd., Quoine Vietnam Co. Ltd., SNG INVESTMENTS YATIRIM VE DANIŞMANLIK ANONİM ŞİRKETİ, Strategy Ark Collective Ltd., Technology Services Bahamas Limited, Tigetwit Ltd., TransferZero, Verdant Canyon Capital LLC, West Innovative Barista Ltd., West Realm Shires Financial Services Inc., West Realm Shires Services Inc., Western Concord Enterprises Ltd., and ZUBR Exchange Ltd. at the U.S. Bankruptcy Court for the District of Delaware.

FTX Trading Ltd. et al: Chapter 11 Petition

Chapter 11 Petition by 134 entities comprising the FTX Group, including those in Antigua and Barbuda, Australia, Bahamas, British Virgin Islands, Canada, Cayman Islands, Cyprus, Egypt, Germany, Ghana, Gibraltar, Hong Kong, India, Ireland, Japan, Kenya, Liechtenstein, Nigeria, Panama, Senegal, Seychelles, Singapore, South Africa, South Korea, Switzerland, Tanzania, Turkey, Uganda, United Arab Emirates, USA, and Vietnam, namely Alameda Aus Pty Ltd., Alameda Global Services Ltd., Alameda Research (Bahamas) Ltd., Alameda Research Holdings Inc., Alameda Research KK, Alameda Research LLC, Alameda Research Ltd., Alameda Research Pte Ltd., Alameda Research Yankari Ltd., Alameda TR Ltd., Alameda TR Systems S. de R. L., Allston Way Ltd., Altalix Ltd., Analisya Pte Ltd., Atlantis Technology Ltd., B for Transfer Egypt, B Payment Services Nigeria, B Transfer Services Ltd., B Transfer Services Ltd. UAE, B Transfer Services Uganda, Bancroft Way Ltd., BitPesa Kenya Ltd., BitPesa RDC SARL, BitPesa Senegal Ltd., BitPesa South Africa, BitPesa Tanzania Ltd., BitPesa Uganda Ltd., Bitvo, Inc., Blockfolio Holdings, Inc., Blockfolio, Inc., Blue Ridge Ltd., BT Payment Services Ghana, BT Payment Services South Africa, BT Payments Uganda, BT Pesa Nigeria Ltd., BTC Africa S.A., BTLS Limited Tanzania, Cardinal Ventures Ltd., Cedar Bay Ltd., Cedar Grove Technology Services, Ltd., Clifton Bay Investments LLC, Clifton Bay Investments Ltd., CM-Equity AG, Corner Stone Staffing, Cottonwood Grove Ltd., Cottonwood Technologies Ltd., Crypto Bahamas LLC, DAAG Trading, DMCC, Deck Technologies Holdings LLC, Deck Technologies Inc., Deep Creek Ltd., Digital Custody Inc., Euclid Way Ltd., Exchange 4 Free Seychellen, Exchange 4Free Australia Br., Exchange 4Free Ltd., Exchange 4Free South Africa Br., Exchange 4Free Swiss Branch, Finfax Company, FTX (Gibraltar) Ltd., FTX Canada Inc., FTX Certificates GmbH, FTX Crypto Services Ltd., FTX Digital Assets LLC, FTX Digital Holdings (Singapore) Pte Ltd., FTX EMEA Ltd., FTX Equity Record Holdings Ltd., FTX Europe AG, FTX Exchange FZE, FTX Hong Kong Ltd., FTX Japan Holdings K.K., FTX Japan K.K., FTX Japan Services KK, FTX Lend Inc., FTX Marketplace, Inc., FTX Products (Singapore) Pte Ltd., FTX Property Holdings Ltd., FTX Services Solutions Ltd., FTX Structured Products AG, FTX Switzerland GmbH, FTX Trading GmbH, FTX Trading Ltd., FTX Turkey Teknoloji ve Ticaret AŞ, FTX US Derivatives LLC, FTX US Services, Inc., FTX US Trading, Inc., FTX Vault Trust Company, FTX Ventures Ltd., FTX Ventures Partnership, FTX Zuma Ltd., GG Trading Terminal Ltd., Global Compass Dynamics Ltd., Good Luck Games, LLC, Goodman Investments Ltd., Hannam Group Inc., Hawaii Digital Assets Inc., Hilltop Technology Services LLC, Hive Empire Trading Pty Ltd., Innovatia Ltd., Island Bay Ventures Inc., K-DNA Financial Services Ltd., Killarney Lake Investments Ltd., Ledger Holdings Inc., LedgerPrime Bitcoin Yield Enhancement Fund, LLC, LedgerPrime Bitcoin Yield Enhancement Master Fund LP, LedgerPrime Digital Asset Opportunities Fund, LLC, LedgerPrime Digital Asset Opportunities Master Fund LP, Ledger Prime LLC, LedgerPrime Ventures, LP, Liquid Financial USA Inc., LiquidEX LLC, Liquid Securities Singapore Pte Ltd., LT Baskets Ltd., Maclaurin Investments Ltd., Mangrove Cay Ltd., North Dimension Inc., North Dimension Ltd., North Wireless Dimension Inc., Paper Bird Inc., Pioneer Street Inc., Quoine India Pte Ltd., Quoine Pte Ltd., Quoine Vietnam Co. Ltd., SNG Investments Yatirim ve Danişmanlik AŞ, Strategy Ark Collective Ltd., Technology Services Bahamas Limited, Tigetwit Ltd., TransferZero, Verdant Canyon Capital LLC, West Innovative Barista Ltd., West Realm Shires Financial Services Inc., West Realm Shires Services Inc., Western Concord Enterprises Ltd., and ZUBR Exchange Ltd. at the U.S. Bankruptcy Court for the District of Delaware.
Jeremy Leach-Managing Partners

British fund manager Jeremy Leach and his firms settle fraud litigation for $11.5M

Four days before a trial was due to start in the Cayman Islands, British fund manager Jeremy Leach and eight of his firms settled a fraud complaint by agreeing to pay $11.5 million over 22 months, OffshoreAlert can reveal. Despite a plethora of red flags, the Cayman Islands Monetary Authority continues to license Leach's Managing Partners Group and its funds and the group also operates entities in the British Virgin Islands, England, Malta, Spain, and Switzerland.

USA v. Nancy Metzler et al: Amended Complaint (‘Undisclosed Swiss & UK Accounts’)

Amended Complaint to collect penalties totaling $590,000 from the Estate of Narinder Singh, who "willfully failed to disclose" five accounts at at Union Bancaire Privée in Switzerland and one at Barclays Bank PLC in the United Kingdom whose "highest aggregate balance" in 2011 was "more than $7.2 million" in USA v. Nancy Metzler and Shalu Arjomand, each in their capacity as Executor for the Estate of Narinder Singh, at the U.S. District Court for the Southern District of New York.

SSD Investments Ltd. et al v. Wilmington Savings Fund Society FSB et al: Complaint

Complaint by entities in Canada, Cayman Islands, Denmark, England, Ireland, Luxembourg, Netherlands, New Zealand, Switzerland, and USA alleging they were victims of a "Sham Transaction" in SSD Investments Ltd. et al v. Wilmington Savings Fund Society FSB et al at the Supreme Court of the State of New York, County of New York.

ParaFi Digital Opportunities LP et al v. Mikhail Egorov: Complaint (‘Crypto Fraud’)

Complaint alleging fraud in ParaFi Digital Opportunities LP, of Delaware; Framework Ventures LP, of Delaware, and 1kx LP, of the Cayman Islands v. Mikhail 'Michael' Egorov, described as resident of Switzerland who "renounced his U.S. permanent residence" and "founder of the “Curve” cryptocurrency trading platform", at the Superior Court of the State of California.

Abdulrahman Mutabagani v. Muhammad Samer bin Mahmoud Abdul-Hadi et al: Discovery Application (Saudi Arabia)

Application by Abdulrahman Mutabagani , described as a citizen and resident of Saudi Arabia, to take discovery from Muhammad Samer bin Mahmoud Abdul-Hadi, described as "a Saudi Arabian citizen who resides in New York", and JPMorgan Chase Bank NA for use in legal proceedings in Saudi Arabia "against Mr. Abdul-Hadi for breach of contract, among other potential causes of action, based on this wrongful conduct" to recover $41 million, filed at the U.S. District Court for the Southern District of New York.

Jonah Meer v. HSBC et al: Discovery Application (British Virgin Islands)

Application by Jonah Beer, as the liquidator of Kopist Holding Limited, to take discovery from H.S.B.C. Bank U.S.A., N.A., Bank of New York Mellon, JPMorgan Chase Bank, N.A., Citibank N.A., Deutsche Bank and its affiliates Deutsche Bank Trust Company Americas and Bankers Trust Company, Commerzbank AG, Wells Fargo Bank, N.A., Bank of America, N.A., Credit Suisse AG, Garanti Bank and Bank Julius Baer for use in legal proceedings in the British Virgin Islands "to recover assets which may have been diverted from the Company", filed at the U.S. District Court for the Southern District of New York.

Axtra LLC et al v. AXIA Issuer Inc. et al: Defendants’ Motion to Dismiss (Crypto Dispute)

Defendants' Motion to Dismiss regarding a dispute involving digital assets in Axtra LLC, of Wyoming, and The AXIA-Axtra Trust, described as “a unit trust formed under the laws of the Cayman Islands” v. AXIA Issuer Inc., described as "a for-profit corporation incorporated in the British Virgin Islands" whose "sole director ... is a corporation domiciled in Nevis", and AXIA Foundation Inc., described as “a non-profit corporation incorporated in the Commonwealth of Dominica” whose directors reside in Canada and Dominica, at the U.S. District Court for the District of Wyoming.

USA v. Narinder Singh: Complaint (‘Unreported Offshore Accounts’)

Complaint to collect unpaid penalties of $590,000 that were imposed for "willful violations" of the Bank Secrecy Act by failing to disclose accounts at Union Bancaire Privée in Switzerland and Barclays Bank Plc in the United Kingdom in USA v. Narinder Singh at the U.S. District Court for the Southern District of New York.

Spring Mountain Vineyard Inc. et al v. MGG California LLC et al: Complaint (‘$185M Loan Enforcement’)

Complaint alleging "an overzealous lender's improper efforts to enforce draconian provisions of a loan document that violate (and are unenforceable under) established New York law" in Spring Mountain Vineyard Inc. and Jacob E. Safra, a.k.a. Jaqui Safra, of Switzerland v. MGG California LLC, MGG (BVI) Limited, of the British Virgin Islands; MGG Canada Fund LP, of Canada; MGG Insurance Fund Series Interests of the Sali Multi-Series Fund LP, MGG Onshore Funding II LLC, MGG SF Drawdown Master Fund (Cayman) LP, of the Cayman Islands; MGG SF Drawdown Unlevered Fund II LP, MGG SF Drawdown Unlevered Fund LP, MGG SF Drawdown Unlevered Master Fund II (Cayman) LP, of the Cayman Islands; MGG SF Evergreen Fund LP, MGG SF Evergreen Master Fund (Cayman) LP, of the Cayman Islands; MGG SF Evergreen Unlevered Fund LP, MGG SF Evergreen Unlevered Master Fund II (Cayman) LP, of the Cayman Islands; MGG Specialty Finance Fund II LP, and MGG Specialty Finance Fund LP at the Supreme Court of the State of New York, County of New York.